In addition to the numerous civil penalties potentially facing taxpayers who fail to participate in the Offshore Voluntary Disclosure Program, there are also some serious criminal charges that may result if the IRS
At the end of the Offshore Voluntary Disclosure Program process, the IRS will attempt to come to a closing agreement with the taxpayer.
The IRS Criminal Investigation division has a longstanding practice of considering a taxpayer’s timely, accurate, and complete voluntary disclosure in determining whether or not to pursue criminal prosecution against the taxpayer.
A previous article on this topic addressed the civil penalties potentially applying to taxpayers who qualify for the Offshore Voluntary Disclosure Program but fail to apply.
If you are preparing for a Tax Court trial, you likely have many questions regarding what to expect.
Receiving a statutory notice of deficiency is a turning point for the taxpayer’s tax litigation case.
In order to qualify for the Offshore Voluntary Disclosure Program, a taxpayer must comply with all the requirements set forth by the IRS.
When a taxpayer decides to pursue tax litigation against the IRS, he or she generally has three choices for judicial forum: Tax Court, the Claims Court, and Federal District Court.
When facing off against the IRS for whatever reason, there is always a process for escalation wherein if your case is not resolved you can seek the attention of a higher authority.
Sometimes, it is in the best interest of the taxpayer to make a refund claim instead of file a deficiency action in the Tax Court.